Gold Coast Airport (GCA) ILS development facilitates provisions for increased runway operational length south.
Attached is the final design of the ILS development footprint on the NSW Crown Reserve for Public Recreation/Conservation with construction to commence shortly. The additional element in the footprint on the Reserve immediately adjacent to the GCA’s southern boundary that has never appeared before and perfectly aligns to the runway speaks volumes.
The final design now confirms there is an additional approx.150m development footprint on the Reserve than required for the ILS. All documentation through the entire ILS process including approval is that the localiser antenna is to be located 300m from runway 14 end. Runway 14 is 2,342m with a Runway End Safety Area (RESA) and runway strip of approx. 150m beyond runway 14 end. The additional development footprint (clearing/earthworks) on the Reserve allows for the increase in the operational length of the runway as detailed in GCA documents, “the southernmost part of the runway itself functions as a defacto RESA, thus reducing the runway’s operational length for takeoffs to the south. The implementation of the RESA on land to the south will improve that operational length”. The additional clearing on the Reserve under the guise of the ILS also facilitates the proposed relocation of the runway 32 landing threshold approx. 300m south re the new Obstacle Limitation Surface (OLS) that will be required.
Under the current operational capacity of the runway there is an existing airside perimeter road with access onto the Reserve and with some extension of that access would provide access to the localiser antenna, runway 14 near field monitor antenna and localiser building. However, to increase the operational length of the runway certainly requires the relocation of the part of the airside perimeter road at the southern end of the runway and extension of the airside perimeter road onto the Reserve which was included in the ILS approval.
Under the Airports Act (Section 89 (ba) altering of a runway requires a Major Development Plan (MDP) that includes consultation. The additional ILS development footprint on the Reserve facilitating an increase in the operational length of GCA’s runway was not disclosed in the ILS MDP.
That ASA is the proponent and under the guise of GCA’s ILS has included an additional footprint requiring additional clearing and earthworks which allows for an increase in the operational length of GCA’s runway when they have no authority for those elements of the development is a most serious matter and contrary to the requirements under Commonwealth and State regulations.
There remains no approvals for the ILS development on the Reserve as legally required under the legal obligations pursuant to a number of conditions of GCA’s Crown Lease over the Crown Reserve.
The extension of the airside perimeter road on the west forms a permanent barrier that will significantly alter tidal inundation patterns and clear passage of tides, significantly impeding groundwater recharge on the west side of the tunnel where severe oxidation of soils and acid/heavy metal contamination of groundwater previously occurred adjacent to the tunnel, thus will seriously exacerbate existing ASS groundwater acid and heavy metal levels. The known severity of these existing ASS conditions that occurred were never disclosed through the entire Commonwealth approval process.
The impacts to this highly significant and sensitive lower Tweed River ecosystem, NSW Class 1 major fish habitat and Tweed Heads West flood patterns will be a long term economic, social and environmental hazard.
Please raise these matters with our Federal and State members and local Councillors to ensure proper due process prevails. And please fwd onto your networks.
Many thanks.
Lindy Smith
